10. Current use and legislation of HFOs in the selected countries

This section provides an overview of key global agreements and EU regulations that shape the current HFO relevant political landscape across the Nordic countries. The focus will be on those with relevance for end-of-life treatments, as well as a brief description of upcoming revisions of existing regulation and the proposed ban on PFAS currently being processed at ECHA. Furthermore, it sums up the sectors where HFOs have been identified to be used and where waste will be generated.

10.1 Global Agreements on F-gases or with relevance to F-gases

10.1.1 The Vienna Convention, the Montreal Protocol, and the Kigali Amendment

In response to the depletion of the ozone layer, the Vienna Convention was adopted in 1985 to protect human health and the environment against the adverse effects of UV radiation. The Vienna Convention aims to monitor and observe the ozone layer, providing the parties to the ozone treaties with a sound knowledge foundation for their decisions.

Ozone Secretariat (2019)

In 1987, the Montreal Protocol was established to phase out the production and consumption of ozone-depleting substances, including CFCs, HCFCs and halons. The Montreal Protocol went into force in 1989. Since its establishment, the Montreal Protocol has been amended several times. So far, the global phase-out is proceeding on schedule.

The latest amendment to the Montreal Protocol is the Kigali Amendment from 2016; the protocol was amended to regulate HFCs and initiate a phase-down of both the production and the consumption of HFCs due to their high GWP. The Kigali Amendment went into force in 2019 and the measures started immediately for non-article 5 parties (industrialised countries). According to the timeline in the Kigali Amendment, the consumption and production of HFCs (all HFCs are listed in Annex F of the Kigali Amendment) for non-article five parties shall be cut down by 85% by 2036 compared to the baseline (based on previous consumption of HFC and HCFC). Article 5 parties have more lenient timelines and are scheduled to reduce production and consumption from 2029 and, for others, not before 2032.

Ozone Secretariat (2018a)

Reducing emissions of HFCs remains within the remit of the UNFCCC and the Paris Agreement.

EEA (2020)

10.1.2 United Nations Framework Convention on Climate Change (UNFCCC)

As Parties to the UNFCCC and Annex 1 Parties to the Kyoto Protocol adopted in 1997, the Nordic countries are required to cut their GHG emissions and report annual greenhouse gas inventories of GHGs not controlled by the Montreal Protocol. The Paris Agreement adopted in 2015 introduces an enhanced transparency framework, including requirements for reporting annual GHG inventories.

EC (n.d.a) & UNFCCC (n.d.)

The gases that require reporting are CO₂, CH₄, N₂O, HFCs, PFCs, SF₆, and NF₃

NH₃ was added to the list of Annex A Greenhouse Gases with the Doha amendment in 2012.

; HFOs are omitted. The Parties are encouraged to report on additional GHGs for which 100-year GWP values are available from the IPCC.

IPCC (2022)

10.2 EU Regulation with Relevance to HFOs

The first generations of F-gases are potent GHGs with high global warming potentials (GWPs). F-gases have, therefore, been regulated in the EU since 2006. Stricter regulations were imposed with the revised F-gas Regulation from 2014 and after the ratification of the Kigali Amendment in 2016. The 2014 F-gas Regulation mandates companies to report on their annual production, import, export, feedstock use and destruction of F-gases listed in Annexes I and II of the regulation. The reporting requirements only apply when the amounts of F-gases exceed a specific quantity.

EU is on track with the Kigali Amendment and the EU F-gas Regulation’s prescription of the HFC phase-down. F-gas emissions are still a cause for concern. In 2021, F-gases were estimated to account for approximately 2.4% of the total GHG emissions in the EU, and HFCs account for most F-gas emissions in the EU.

EEA (2023)

The F-gas Regulation regulates substances according to their GWP values and uses ton CO₂eq as the quantitative measurement to set thresholds instead of the amount of substance by mass. Therefore, legislation seldom affects HFOs due to their low GWP. This section briefly describes the most relevant regulations and directives at the EU level.

10.2.1 The End-of-life Vehicles Directive

The most recent amendment of the EU Directive 2000/53/EC for end-of-life vehicles was in 2018.

Directive (EU) 2018/849

Annex I describes the required treatment operations for depolluting EOL vehicles, including:

Removal and separate collection and storage of fuel, motor oil, trans mission oil, gearbox oil, hydraulic oil, cooling liquids, antifreeze, brake fluids, air-conditioning system fluids and any other fluid contained in the End-of-life vehicle, unless they are necessary for the re-use of the parts concerned
Directive 2000/53/EC

10.2.2 The MAC Directive 2006/40/EC

The purpose of Directive 2006/40/EC on mobile air-conditioning systems (MAC Directive) is to reduce emissions of fluorinated greenhouse gases from air conditioning in passenger cars and light vans. The directive introduced a gradual ban on using F-gases with a GWP higher than 150 in all new vehicles. The directive was fully implemented in 2017. The directive does not provide guidance on what alternative refrigerants to use instead of those previously applied. As long as the substance of choice has a GWP below 150, it is up to the industry to decide which refrigerant to use. Due to the MAC Directive, the previous MAC refrigerant of choice, HFC-134a (GWP 1430), has been replaced mainly by HFO-1234yf in new passenger vehicles.

Directive 2006/40/EC.

R-744 is also used in some new vehicles.

10.2.3 The Waste Framework Directive 2008/98/EC,

The Waste Framework Directive is the key legislative document on waste in the EU. The directive defines waste and provides the legislative framework for how it should be handled and establishes the waste hierarchy. The Waste Framework Directive also determines that hazardous waste may only be treated at treatment facilities that have obtained a special permit (required under Articles 23 to 25).

In the European List of Waste (LoW), CFCss, HFCFCs and HFCs are listed in Chapter 14 ‘WASTE ORGANIC SOLVENTS, REFRIGERANTS AND PROPELLANTS (except 07 and 08), and have the waste classification code 14 06 01*. They are classified as hazardous waste, as indicated by the asterisk.

End-of-life vehicles from different means of transport (including off-road machinery) and waste from dismantling end-of-life vehicles and vehicle maintenance (except 13, 14, 16 06 and 16 08) have waste code 16 01.

Waste from electrical and electronic equipment has waste code 16 02. Entry 16 02 11* covers ‘discarded equipment containing CFCs, HCFCs and HFCs.

Decision 2014/955/EU

Whether HFOs are included in these categories or considered as hazardous wastes is unclear. Chapter 12 further elaborates whether the different countries that are a part of this study, considers HFOs as hazardous waste.

10.2.4 The WEEE Directive 2012/19/EU

HFOs are also used in products and equipment that fall under the definition of the WEEE Directive. The Directive on waste electrical and electronic equipment (WEEE) 2012/19/EU requires the separate collection and proper treatment of WEEE and implements the producer responsibility principle. The first WEEE directive entered into force in 2003; a revised WEEE directive went into force in 2012. Large household appliances such as refrigerators, freezers, electric heating appliances and air conditioner appliances etc., are covered by the EU WEEE directive:

Directive 2012/19/EU

Article 8 Proper treatment:
2. Proper treatment other than preparing for re-use, and recovery or recycling shall, as a minimum, include the removal of all fluids and a selective treatment in accordance with Annex VII.

1. As a minimum the following substances, mixtures and components have to be removed from any separately collected WEEE: (…) chlorofluorocarbons (CFC), hydrochlorofluorocarbons (HCFC) or hydrofluorocarbons (HFC), hydrocarbons (HC).

2. The following components of WEEE that is separately collected have to be treated as indicated: (…) equipment containing gases that are ozone depleting or have a global warming potential (GWP) above 15, such as those contained in foams and refrigeration circuits: the gases must be properly extracted and properly treated. Ozone-depleting gases must be treated in accordance with Regulation (EC) No 1005/2009

10.2.5 The EU F-gas Regulation 2014/517/EU

The EU F-gas Regulation 517/2014 is the primary regulation of relevance for F-gases.

Regulation (EU) No. 517/2014

It prohibits intentional and unintentional emissions of F-gases in different ways and sets requirements for documentation of recovery and disposal. F-gases have been regulated in the EU since 2006. It aims to protect the environment by limiting the total amount of F-gases imported and produced in the EU, restricting the use of high GWP F-gases in certain types of equipment and appliances and totally banning the use of F-gases in certain appliances and preventing emissions from existing equipment and appliances by requiring qualified maintenance and installation. The regulation requires companies to report on produced, imported, and exported quantities of F-gases and mixtures.

The current F-gas Regulation 517/2014 went into force in 2015, replacing the former. Relevant measures from the preceding F-gas Regulation remain in place. The current F-gas Regulation aims to reduce F-gas emissions by two-thirds by 2030 compared to 2010, and the regulation introduced a phase-down timeline that started in 2015. The HFC phase-down is being implemented by annual quotas that are gradually being reduced; the quotas are putting quantitative limits on the placement of HFCs on the EU market by producers and importers.

EEA (2020)

With the revised regulation, other fluorinated greenhouse gases, in addition to those listed in Annex I, became subject to reporting in accordance with Article 19 of the regulation. The other fluorinated greenhouse gases are listed in Annex II of Regulation 517/2014, including several HFO substances. The following HFOs (termed unsaturated hydro(chloro)fluorocarbons in the regulation) are listed in Annex II, section 1:

HFC-1234yf
HFC-1234ze
HFC-1223zd
Regulation (EU) No. 517/2014

Article 19 describes reporting requirements on the production, import, export, feedstock use, and destruction of the substances listed in Annex I and Annex II. Reporting is only required beyond the following listed quantities:

Each producer, importer and exporter that produced, imported, or exported one metric tonne or 100 tonnes of CO₂eq.
Each undertaking that destroyed one metric tonne or 1000 tonnes of CO₂eq.
Each undertaking that used 1000 tonnes of CO₂eq or more as feedstock.
Each undertaking that placed 500 tonnes of CO₂eq or more contained in products or equipment on the market.

Furthermore:

Each importer of equipment that is placed on the market pre-charged equipment where hydrofluorocarbons contained in this equipment have not been placed on the market prior to charging the equipment.
Regulation (EU) No. 517/2014

HFOs are only partly covered by Regulation 517/2014 as an Annex II gas, and due to the low GWP of HFOs, article 19 reporting requirements rarely step into force for POM equipment. For the import of bulk gas, the report threshold limit is 1 metric tonne or 100 t CO₂eq. Besides Article 19, Article 7 also includes Annex II gases. Article 7(2) prohibits placing any Annex I or Annex II substances on the market unless relevant producers and importers can provide evidence that any trifluoromethane (HFC-23: GWP 12,690) produced as a by-product in the manufacturing of the substance or the manufacturing of any feedstock used for their production has been either destroyed or recovered for other use in line with best available techniques (BAT).

Regulation (EU) No. 517/2014

10.2.6 Potential Future Developments in the EU Regulation

The EU Commission has proposed a new F-gas Regulation that will repeal Regulation (EU) No 517/2014 to better align the regulation with the European Green Deal and the European Climate Law.

EC (n.d.b)

The proposal was published in April 2022 and is currently being negotiated by the EU Parliament and the Council. The impact assessment report that accompanied the new proposal highlighted a large gap for importers of HFO equipment, e.g., MAC systems, when the reporting threshold is defined in CO₂ equivalents.

Gschrey et al (2022)

In the new proposal, HFOs listed in Annex II Section 1 are more extensively covered by the regulation and are, for instance, included in Article 4, Prevention of Emissions, Article 8, Recovery and Destruction and Article 10, Certification and Training. Furthermore, two new HFO substances are added to Annex II Section 1:

EC (2022a)

HFC-1132, a new MAC refrigerant
HFC-1132a, part of new refrigerant blends

Barriers to effective implementation of Regulation 2014/517/EU identified in the impact assessment report include:

Safety codes for climate-friendly alternatives have yet to be updated accordingly with technological progress, and this includes existing restrictions on flammable refrigerants that need to be updated.
Technical barriers in building codes
Lack of qualified service personnel to install climate-friendly alternatives
Imports of HFCs outside of the quota system
Since HFOs are listed in Annex II, they are not covered by the measures that aim at preventing their emissions. Annex II gases are not subject to emission controls
The current regulation was considered less effective in preventing the leaking of other uses and substances than HFCs
The requirement to prevent emissions during production, transport and storage applies to producers only and not any other actors.
HFC recovery from foams at end-of-life is only required where it is ‘technically feasible and does not entail disproportionate cost’. In practice, this has resulted in very little recovery, and the provision is difficult to enforce for authorities.

(European Commission (2022). Commission staff working document impact assessment report accompanying the document proposal for a regulation of the European Parliament and of the Council on fluorinated greenhouse gases amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014)

A potential ban on per- and polyfluoroalkyl substances (PFAS)

In January 2023, Denmark, Germany, the Netherlands, Norway, and Sweden submitted a proposal to restrict PFAS. Their suggested definition of PFAS: “Substances that contain at least one fully fluorinated methyl (-CF3) or methylene (-CF2-) carbon”

ECHA (2023)

will extend the ban to cover at least the following market-available HFO substances:

HFO1234yf
HFO1234ze(E)
HFO1336mzz(E)
HFO1336mmz(Z)

ECHA has also submitted a proposal to restrict PFAS in fire-fighting foams.

ECHA (2022)

10.2.7 European Challenges

There are several obstacles to the phase-down of HFCs. According to the European Installers’ Association AREA, only 3.5–7% of certified F-gas personnel were trained in alternatives such as natural refrigerants and HFOs, and only half of the training centres in the EU offer training on alternative refrigerants.

EC (2022a)

10.3 Legislation in the countries covered by the study

This section provides a cross-country summary, presenting the key findings from the country studies and highlighting differences between the countries and where the countries have gone beyond the EU legislation, with a special focus on to what extent HFOs are included, explicitly excluded or whether it is not explicitly stated.

Most of the legislation across the Nordics is based on EU regulation, including for the non-member countries. Denmark, Finland, Germany, and Sweden are all members of the EU. Iceland and Norway are not EU members but are part of the EEA area. The Faroe Islands and Switzerland are neither an EU member nor part of the EEA area, Switzerland is a member of the European Free Trade Organisation (EFTA). Most of the legislation across the Nordics is based on EU regulation, including for the non-member countries.

The complete individual country studies are attached in Appendix 1. This section provides a cross-country summary, presenting the key findings from the country studies and highlighting differences between the countries and where the countries have gone beyond the EU legislation, with a special focus on to what extent HFOs are included, explicitly excluded or whether it is not explicitly stated.

10.3.1 F-gas Regulation

Denmark, Germany, Finland, Norway, and Sweden have all implemented the EU F-gas Regulation (517/2014). In Iceland, fluorinated GHGs are covered by Regulation No 1066/2019, which implements Regulation (EC) No 517/2014 for certain F-gases, HFOs not included.

Regulation (EU) No. 517/2014

Another notable exemption is that both Iceland and Norway have their own quota system and is not included in the EU Commission’s quota system.

Umhverfis Stofnun, n.d.

The Faroe Islands do currently not have any legislation on F-gases. The Faroe Parliament are currently in the process of adopting a regulation on F-gases; however, HFOs are not explicitly included in the new proposed legislation.

Umhvørvisstovan (2023)

Finland

The Finnish training and certification scheme goes beyond the EU F-gas Regulation since all garages need to be certified, and the scheme covers all mobile equipment and activities such as recovery, installation, and repair.

Birchby et al (2022)

A governmental decree from 2016 outlay required qualifications for handling vehicle equipment containing fluorinated greenhouse gases. The act describes the requirements for the operator and individuals working with the installation, maintenance, reparation, refilling, decommission and recycling of refrigerants. They are defined according to the definition of fluorinated greenhouse gases in the EU F-gas Regulation (517/2014), and HFOs are therefore not included. HFOs are not listed in the annex specifying different refrigerants. However, any blends containing fluorinated greenhouse gases are subject to the requirements. The requirements differ depending on whether the equipment contains less or at least 3 kg or more refrigerant. All require a certain level of education.

Tukes (2016)

Sweden

Sweden has also implemented Regulation (SE) No 2016:1128,

SFS 2016:1128

which complements the (EC) NO 517/2014 regulation. The regulation provisions that leakage check requirements and certified competence also apply to mobile equipment containing F-gases. Moreover, that upon disposal, those who supply refrigerants are required to take these back and provide containers for this purpose free of charge.

SFS 2016:1128

There is no refund for returning F-gases in Sweden.

Regulation 2016:1128 uses the same F-gas definition as in (EU) no. 517/2014 article 2.1. HFOs are, therefore, not covered by the regulation. However, the regulation states that if a system containing 14 tons CO₂eq or more is to be converted to another refrigerant than HFC, it needs to be reported to the authorities.

SFS 2016:1128

Denmark

BEK nr. 1013 af 13/05/2021 prescribes further requirements in addition to the EU legislation. The regulation explicitly omits HFOs, including when part of a blend with other refrigerants covered by the legislation.

BEK nr 1013 af 13/05/2021

The Danish Environmental Protection Agency are responsible for enforcing the regulations.

Germany

Take-back facilities depend on the specific refrigerant and the type of systems, but it is often done via gas trades or waste management companies. Germany implemented a legally binding take-back scheme in 2009. Section 4 of the German Federal Chemicals Climate Protection Ordinance states that producers and distributors must take back HFC refrigerants after they have been recovered.

Chemikalien-Klimaschutzverordnung (2008)

Distributors and producers can charge contractors a fee when they hand in HFC refrigerants, this has been identified as a limiting factor for the scheme since it discourages some from delivering recovered refrigerants since it is associated with a cost.

EIA (2016)

Switzerland

In Switzerland, F-gases are regulated under the Chemical Risk Reduction Ordinance (ORRChem).

Annex 1.5 ORRChem includes regulation for the import, export, and general use of F-gases.
Annex 2.3 covers the use of solvents.
Annex 2.9 covers the use of foams.
Annex 2.10 covers the use of refrigerants.
Annex 2.11 covers the use of extinguishing agents.
Annex 2.12 covers the use of aerosols.

The manufacture, installation, maintenance or disposal of refrigeration, air conditioning or heat recovery appliances or systems requires a License. Licenses from EU and EFTA member states are considered equivalent to the Swiss certificate.

ORRChem (2005)

HFOs are not regulated in Switzerland only if they are contained in blends with other F-gases. However, there are reporting requirements for any equipment that uses more than 3 kg of refrigerant, no matter the type of refrigerant.

FOEN (2023)

10.3.2 End-of-life vehicle directive:

Denmark, Finland, Germany, Iceland, Norway and Sweden have all implemented the directive.

10.3.3 WEEE regulation

Denmark, Germany, Finland, Norway and Sweden have all transposed the EU Directive 2012/19 on WEEE into national law. Regulation 1061/2018 in Iceland is the primary regulation on waste electrical and electronic equipment. This largely adopts the EU Directive on WEEE (2012/19).

Directive (EU) 2012/19

Appendix I in the Icelandic regulation 1061/2018 clearly defines the equipment relevant for the current compounds of interest – “heat exchangers”. This is also the case for the EU 2012/19 regulation, but the Icelandic list is less comprehensive.

Switzerland has adopted The Ordinance on the Return, Take-back and Disposal of Electrical and Electronic Equipment (ORDEE), which requires Producer responsibility for the take-back of electrical and electronic equipment. The Ordinance came into force in 1998.

10.3.4 The Waste Framework Directive

The Danish, German, Finnish, Icelandic, Norwegian and Swedish waste regulation follows European legislation. In the Faroe Islands, waste handling is regulated by the Environment Protection Act, adopted in 1988 and the order on waste, which has been amended several times. The law encompasses activities from which liquid, solid or gaseous substances can pollute the Faroese territory's air, earth, and water bodies.

Sæmundsdóttir (2021)

10.3.5 The MAC Directive

The MAC directive is implemented by all countries EU and EEA countries.

10.3.6 Taxation and Refund Schemes

There are no taxes on HFC or other refrigerants in the Faroe Islands, Finland and Sweden or any other money-based take-back schemes.

Sæmundsdóttir (2021)

In the Faroe Islands, the regulation on taxes on F-gases was in hearing in August 2023. The taxes are expected to come into force on January 1^st 2024.

Iceland

Icelandic Recycling fund

In Iceland, The Icelandic Recycling Fund aims to secure (economical) means for handling waste in Iceland

Úrvinnslusjóður (n.d.).

by leaning on the principle of “polluter pays”. This is mandated through Law no. 162/2002 on processing fee.

Lög nr. 162/2002

Part of this legislation and taxation is directed at refrigerants, as described in Article 8, point 9. Appendix XV further extrapolates which specific refrigerants are taxed in which amount (even though every refrigerant on the list is currently taxed the same amount). HFOs are implied in this taxation under “3824.9006: Other refrigerants” in Appendix XV. The tax is collected as an expedition fee through import and is currently priced at 2,5 ISK/kg for every kind of refrigerant. The money is collected for The Icelandic Recycling Fund to pay for the waste handling this fund is responsible for. 0.5% is going to an administration fee to the Treasury. Before January 1^st, 2003, it cost 98 ISK/kg in import duty for all refrigerants.

Brynjarsson & Hilmarsson (2020)

In other words, the tax has been lowered considerably. Some argue that this tax (regarding f-gases) costs more to upkeep administratively than it is worthwhile because few claims the fund to the degree it was planned for. The tax was lowered because of a significant operating profit for refrigerants accumulated; each year, a couple of hundred tons of F-gases were imported, but only a few tons were returned for waste disposal.

Brynjarsson & Hilmarsson (2020)

Law on Environmental and Natural Resource Taxes, no. 129/2009

The newest, significant Icelandic regulation (with taxation as the primary instrument) is adopted through Law no. 135: the Act of Amendment of various laws regarding the budget for 2020.

Lög nr. 135/2019

This creates a new chapter in the Law on Environmental and Natural Resource Taxes, no. 129/2009

Lög nr. 129/2009

- Chapter III with articles 13–16. This is the legislative measure with the highest economically significant incitement for reducing the import of high GWP F-gases into Iceland. The amount of import duties to be paid is considerably more significant than the expedition fee for the Icelandic Recycling Fund. According to this legislation, the import duty to be paid for F-gases is between 30 ISK/kg–10,000 ISK/kg. The higher the GWP of the f-gas, the higher the tax is, up to a maximum of 10,000 pr. kg, similar to e.g., Denmark.

Helgadóttir et al (2022)

Article 13 provides a table for specific F-gases and their respective tax price and (UK) customs numbers. The list in the legislative document contains several commonly used HFCs, PFCs and blends. Article 13, §3 stipulates that:

“In the case of imports of fluorinated greenhouse gases other than those specified in paragraph 2. must pay tax based on the following criteria:

For fluorinated greenhouse gases not specified in the 2nd paragraph. must pay tax in the amount of ISK 10,000/kg.
For mixtures not specified in paragraph 2. the amount of tax shall be calculated based on the proportions of the materials that make up the mixture.
For other mixtures not specified in paragraph 2. and the provisions of item 2 cannot be applied. a tax in the amount of ISK 10,000/kg must be paid.” (Law no. 129/2009 [machine translated], 2009).”

If the imported fluorinated GHGs are not listed in Article 13, the tax will be 10,000 ISK/kg. If it is a blend, the price will be determined based on the different components in the blend. Since HFOs are not classified as fluorinated greenhouse gases, there is no taxation on HFOs, and for any blends containing HFOs, that proportion does not count when calculating the price.

Norway

In 2003, Norway implemented an excise duty on the production and import of HFCs and PFCs, and in 2004 a refund scheme for the destruction of HFCs and PFCs was introduced. The tax is refunded to the party delivering the waste to an approved collection point, ensuring proper end-of-life treatment. The tax is NOK 0.952 per kg (2023) multiplied by the GWP potential of the refrigerant.

Returgass (n.d.b)

The excise duty covers the import and production of the following:

"Pure gas products in bulk and import of all types of combination of HFC and PFC, both as known mixtures and in combination with other substances.
Products where the gases are integral components, include air conditioning and refrigeration units, vehicle air conditioning units, expanding foam insulation and aerosol propellants in spray cans."
The Norwegian tax administration (n.d.)

The Norwegian Government plans to increase the taxes on HFCs as part of Norway’s 2021–2030 Climate Action Plan.

Norwegian Ministry of Climate and Environment (2020–2021)

The objective is to create stronger financial incentives for individuals and businesses to opt for climate-friendly alternatives. The tax level is currently set at NOK 952 per ton CO₂eq and is expected to be raised to around NOK 2,000 per ton CO₂eq by 2030. This will also result in a corresponding increase in tax refunds to the operator when handing in the refrigerant for analysis and destruction. The Government considers this substantial increase essential to ensure Norway fulfils their commitment under the agreement with the EU to reduce emissions by 40% by 2030.

Norwegian Ministry of Climate and Environment (2020–2021)

There are currently no taxes on HFOs, and if they were to be included following the same method, the tax would be very low due to the very low GWP of HFOs.

Denmark

Law on taxation of CFC and certain Industrial greenhouse gases LOV nr 448 af 17/04/2020

There is a Danish tax on CFC and certain fluorinated greenhouse gases. The substance’s GWP determines the tax for HFC, PFC and SF6. There is also a tax on HFO-1234ze and HFO-1234yf, currently at 0.17 €/kg.

Danish Refrigerant Installers Environmental Scheme (Kølebranchens Miljøordning (KMO))

KMO (Kørelbranchens Miljøordning) was established in Denmark in 1992, The KMO is a voluntary deposit-refund scheme to manage used refrigerants at end-of-life. In 2020, KMO established a return scheme for flammable refrigerants such as HFOs.

KMO (2020)

New refrigerants are sold with a KMO fee. To some extent, this fee covers the wholesaler's handling costs and the destruction or reuse of the recovered refrigerants. The customers who hand in used refrigerant will get a partial refund. The size of the refund depends on whether the refrigerant is clean or contaminated.

10.4 Use of HFOs in the Nordics

There is a general tendency in the Nordics to prefer and promote natural refrigerants, for instance, through joint Nordic initiatives such as “Nordic Criteria of Green Public Procurement”,

Poulsen & Pedersen (2020)

a report published by the Nordic Council of Ministers that provides resources and guidance for the public administration to avoid the purchase or to find alternatives to appliances containing high GWP F-gases, as well as HFOs wherever possible. But HFOs are in use and are market available in all the Nordic countries.

The following section gives an overview of sectors where HFOs have been identified to be used in the Nordic countries, as well as Germany and Switzerland. HFOs are imported in bulk, and products, both pure HFOs and blends are being imported. Most notably, they are used in the majority of new passenger cars’ AC systems. However, due to HFO's Annex II status in the current EU F-gas Regulation and not being subject to GHG reporting requirements by the UNFCCC, current monitoring of HFOs is limited, and data is limited. According to spokespersons from different organisations in the RACHP sector, some are generally, awaiting the upcoming EU F-gas Regulation and the potential ban on PFAS to consider future ventures.

Svenska Kyl- & varmepumpforeningen (2023) & SKLL (2023)

10.4.1 Import of Bulk HFOs

Denmark: The quantities of HFOs imported in Denmark are increasing. In 2019, 22.7 tonnes of HFOs were imported; in 2020, it was 30.2. tonnes. According to the Danish Tax Agency, the quantities of HFO-1234yf and HFO-1234ze substances imported in 2022 were 30.5 tonnes and 4.2 tonnes, respectively.
The Danish Tax Agency (2023)
The Faroe Islands: There are no reporting requirements for HFOs in the Faroe Islands. However, all registered HFC importers are required to annually supply information to the Environmental Protection Agency. In the reporting format, it is possible to report on other F-gases than HFCs; here, both 1234yf and 1234ze have been reported. R-449 has also been imported, but in very small amounts.
Umhvørvisstovan (2023)
Finland: There is both import and export of HFOs in Finland. The import consists of equipment containing HFO and HFO in bulk. HFOs are primarily imported in equipment, but there has been a significant increase in bulk import in recent years; most are expected to go to MAC applications. Import of the following HFO substances has been identified in Finland: HFO-1234yf, HFO-1234ze(E), HFO-1336mzz(Z) and HFO-1233zd(E).
Syke (2023)
Iceland: Very small amounts of pure HFOs are imported in Iceland annually (a few batches of a couple of kilos). HFOs are primarily imported in blends. The following blends have been identified in the import data since 2016: R-448A, R-449A, R-452A, R-454C, R-455A, R-513A, R-515B. R-449A constitutes the largest share; in 2021, 6.3 tonnes were imported.
Umhverfis stofnun (2023)
Norway: The amounts of imported HFO-1234yf and HFO-1234ze have increased recently in Norway. The quantities of HFO-1234yf and HFO-1234ze substances imported in bulk in 2022 were 22 tonnes and 1.3 tonnes, respectively.
Miljødirektoratet (2023)
In addition to these, HFOs are imported in bulk in blends. Further, there are substantial amounts imported in products, particularly in MAC in passenger cars.

10.4.2 The use of HFOs in the Auto sector

In accordance with the MAC directive (Directive 2006/40/EC), it has been prohibited to use refrigerants with a GWP higher than 150 in new passenger vehicles' AC systems since January 2017. This has resulted in most new cars using HFO-1234yf in their AC system today. In the Nordics, HFO-1234yf first appeared in AC systems of new cars in 2011 and has rapidly increased since then. Car AC systems typically contain 400-1000 grams of refrigerant.

Stiftelsen Returgass & Christonik ApS (2023)

Due to the large number of AC systems, the auto sector is a significant source of emissions.

NRF (2020)

The regulated quality requirements for these AC systems accept an annual leakage of 40 g/year and 60 g/year for systems with multiple evaporators.

EC (n.d.c)

Continued refilling is necessary, and most HFO-1234yf imported is expected to be used for MAC systems.

Iceland: Data obtained for the 2022 National Inventory Report in Iceland showed that all new vehicles imported during 2019 used R-1234yf in their AC system.
Finland: HFO-1234yf has been the refrigerant in all new cars imported and registered in Finland since 2018. It has, however, still been possible to import used cars equipped with HFC-134a. Syke has estimated that of the used vehicles imported in 2020, 80% were equipped with HFC-134a, and 20% were equipped with HFO-1234yf, compared to 90% and 10% in 2018.
Statistics Finland & Ministry of the environment (2022)
In Finland, light-duty vehicles equipped with HFO-1234yf were first reported in 2016, and in 2020, the share of light-duty vehicles using HFO-1234yf constituted 39%. For transport refrigeration, The HFC/HFO blend R-452A was introduced to the market in 2015 and is now widely used in new transport refrigeration equipment.
Statistics Finland & Ministry of the environment (2022)
Germany: (cars). In Germany, they are currently testing using pure HFOs as a refrigerant in small vehicle refrigeration systems.
Umwelt Bundesamt (2023)
Switzerland: In Switzerland, HFO-1234yf is considered the state of art technology for AC systems in passenger cars, and new vehicles are not allowed to use HFC-134a for air conditioning.

10.4.3 The use of HFOs in RACHP

There is a general preference in the Nordics towards using natural refrigerants in cooling systems and heat pumps. But HFOs are in use and market available, both pure HFOs and HFC/HFO blends. Both pure HFOs and HFC/HFO blends are used. In commercial, industrial and transport refrigeration, practically only HFO/HFC blends are used. In stationary AC (incl. heat pumps), pure HFOs and blends are used.

Syke (2023)

Larger RACHP (commercial and industrial use)

In Denmark, Germany, Finland, Norway, Sweden and Switzerland, HFOs have been identified to be used in larger heat pumps and chillers (>100 kWh) installed in commercial buildings and by industry.

Finland: In Finland, there has been data on the instalment of large heat pumps containing HFO-1234ze since 2019, but only a small percentage of annually installed large heat pumps contained HFO-1234ze in 2019 and 2020 (less than 10%). Several other refrigerants are also reported to be used for this type of heat pump, including ammonia and the HFC/HFO blends R-450A and R-513A.
Syke (2023)
Norway: Due to the safety aspects, such as toxicity and flammability when working with ammonia, there is a tendency to use HFO refrigerants in newer plants in Norway. Some newer heat pumps for district heating use HFO1234ze. There are no restrictions on how large fillings the plants can have, and it is not unusual that the filling is several tonnes.
VKE (2023)
Denmark: In Denmark, a large part of imported HFO-1234ze is expected to be used for commercial refrigeration.
Danish Environment Protection Agency (2020)
Germany: In commercial refrigeration, pure HFO-1234ze is used in condensing units as well as several HFO blends in central systems (R-448A, R-449A), condensing units (R-449A, R-452A, R-454C, R-455A, R-513A) and plug-in appliances (R-454C, R-455A).
Numerous refrigerants are used in larger industrial refrigeration and air conditioning in Germany. In centrifugal chillers, it is mainly HFO-1234ze(E) and, to a minor extent, R-1233zd(E). Other chiller types, such as chillers with reciprocating or screw compressors, use R-1234ze(E) and other refrigerants. The blends R-513A and R-515B are also in centrifugal and other chillers.
Switzerland: In Switzerland, it is not allowed to use HFCs in RACHP systems of more than 400 kW, and HFOs are primarily used instead.
Scecho AG (2023)

Domestic Heat pumps

Germany: In domestic heat pumps in Germany, HFOs are not used pure, only in blends. The following blends are used for domestic heat pumps: R-448A, R-449A, R-452B, R-454B, R-454C, R-513A, and R-515B.
Switzerland: In Switzerland, domestic heat pumps mainly use HFC or HFC/HFO blends. The use of hydrocarbons in heat pumps is increasing.

Fishing vessels

Iceland & the Faroe Islands: In Iceland and the Faroe Islands, larger Industrial Fishing vessels mainly use ammonia as an on-ship refrigerant. Smaller fishing vessels use other refrigerants, HFCs or HFC blends. There are currently no natural refrigerant systems for smaller fishing vessels that are technically adequate, so there is a shift potential from HFCs to HFOs for this type of application.
Brynjarsson & Hilmarsson (2020)
However, there is a general shift towards using ammonia and CO₂ on fishing vessels.
Umhvørvisstovan (2023)
Iceland Recycling fund (2023)

10.4.4 The use of HFOs as foam blowing agents

HFO-1234ze is known to be used as a foam-blowing agent, for instance, in XPS foams. In some of the investigated countries, it has been possible to confirm their use mainly in building and construction foams, but to what extent or in what quantities has not been possible to determine. As described in section 6.4.5. and 6.4.6, several natural refrigerants are also used as foam-blowing agents, and other HFO substances than HFO-1234ze are also expected to be used.

Iceland & the Faroe Islands: No use of HFOs was identified in Iceland and the Faroe Islands
Finland: In Finland, HFOs are known to be used as foaming agents.
Norway: HFOs are used as foam-blowing agents in Norway. It has not been possible to gather any data on quantities.
Iceland Recycling fund (2023)
Sweden: According to the latest Swedish national inventory report, an increasing proportion of XPS foams use other blowing agents than HFCs, such as CO₂and HFOs. However, there is not any available data on the proportions.
Naturvårdsverket (2022)
Germany: HFO-1234ze is used as a foam-blowing agent for XPS foam. HFO-1336mzz(Z) is used for PUR foams. Foams in products have not been identified in Germany.
Switzerland: In Switzerland, HFOs are used as a replacement for HFCs as a foaming agent in building and construction foams and foam products.

10.4.5 The use of HFOs as Aerosol propellants

HFO-1234ze is known to be used as an aerosol propellant, and their use in the countries studied has been confirmed through stakeholder interviews, but it has not been possible to determine in what quantities they are on the market.

Finland: In Finland, imports of aerosol sprays containing HFO aerosol propellant have been identified and registered since at least 2018.
Syke (2023)
Iceland & the Faroe Islands: No use was identified in Iceland and the Faroe Islands

Sweden: In Sweden, aerosol sprays with HFOs as aerosol propellants are only expected to be used in insignificant quantities so far. One expert estimates that HFOs will be used much more in the future.
Eco Scandic (2023)
Denmark: According to the Danish National Inventory Report, the previous aerosol propellant HFC-134a was phased out and substituted with HFO-1234ze in 2019 and so forth.
Germany: In Germany, HFO-1234ze is used in aerosols. A blend of R-1234ze(E) and R-134a is used in rare cases, for instance, for electric cooling spray and filling of pressure cushions in heating and tank technology.
Umwelt Bundesamt (2023)
Switzerland: HFOs are in use as an aerosol propellant as a replacement for HFCs.
Umwelt Bundesamt (2023)